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Ninth Circuit Applies Cumulative Harm Standard to Asylum and Withholding of Removal


December 19, 2022
by Sabrina Damast

The Ninth Circuit has reiterated that the agency must asses the cumulative impact of incidents of past harm when determining if an asylum/withholding of removal applicant suffered past persecution.

The full text of Salguero Sosa v. Garland can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2022/12/16/19-70961.pdf

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